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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.2 Settlements with a qualifying interest in possession (QIIP) /Chargeable events during lifetime of a QIIP trust / I5.230 Close companies—alterations in rights attaching to shares: QIIPs
Commentary

I5.230 Close companies—alterations in rights attaching to shares: QIIPs


IHT, trusts and estates

Where there is an alteration before 22 March 206 (including extinguishment1) in either:

  1. Ìý

    •ÌýÌýÌýÌý a close company's share or loan capital (where such capital is not quoted), or

  2. Ìý

    •ÌýÌýÌýÌý the rights attached to shares or debentures in an unquoted close company

and

  1. Ìý

    •ÌýÌýÌýÌý the participators include trustees of a settlement

  2. Ìý

    •ÌýÌýÌýÌý there would be a transfer of value by the trustees if they were beneficially entitled (see I6.111), and

  3. Ìý

    •ÌýÌýÌýÌý an individual is beneficially entitled to an interest in possession under the settlement in the shares or securities,

the

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